Because if you are going to dub something meaningless filler, of course “girls under trees” would be perfect?

Georgetown University Law Center Associate Law Librarian Roger Skalbeck and Yale Law School Librarian for Emerging Technologies Jason Eiseman have published a study entitled “Top 10 Law School Home Pages of 2010.” Here are a couple of excerpts:

On the other side of the diagram, often included on the front page but not something people are looking for is a “Campus Photo Slideshow.” This is true also for law schools which may often include large photos of students, the campus or both. While these illustrations are thought to add an attractive element to a home page, often they are nothing more than filler. In fact eye-tracking studies suggest that such photos may be completely ignored.

In an effort to track this phenomenon we created the “Girls Under Trees” metric, which is more fully explained below. In our study, home pages with pictures of students of any gender under, near or around trees were found on sixty-five home pages. Had we expanded the photo metric to include such clichés as United States Supreme Court Justices, moot court trial teams, or students in class, we may likely find filler images on the majority of home pages. Again while thought to give potential students a taste of law school life, these photos usually do not add any content, context, nor important information for visitors to a site. [emphasis added].

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Girls under Trees [t] – 3 pts. deducted
In 2008 usability expert Jared Spool decried the overuse of pictures of girls under trees in higher education websites. This meme has become a famous cliché in web design circles, mentioned by everyone from web design expert Jeffrey Zeldman to law professor/blogger Ann Althouse. Eye tracking studies suggest that such images are filler which is often ignored by users. Points were deducted for home pages displaying people (of any gender) under, near, or around trees.